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The following Privacy Policy sets out the rules for saving and accessing data on Users' Devices using the Website for the purposes of providing services electronically by the Administrator and the rules for collecting and processing Users' personal data that were provided by them personally and voluntarily through the tools available on the Website.

The following Privacy Policy is an integral part of the Website Regulations , which defines the rules, rights and obligations of Users using the Website.

§1 Definitions

Website - the "Passwords to crosswords" website operating at https://country-atlas.com

External website - websites of partners, service providers or service recipients cooperating with the Administrator

Website / Data Administrator - The Website Administrator and Data Administrator (hereinafter referred to as the Administrator) is the company "SEOPoint Adam Pokora", operating at the address: Sportowa 18, with a tax identification number (NIP): 9880301401, providing electronic services via the Website

User - a natural person for whom the Administrator provides services electronically via the Website.

Device - an electronic device with software through which the User gains access to the Website

Cookies (cookies) - text data collected in the form of files placed on the User's Device

GDPR - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) data)

Personal data - means information about an identified or identifiable natural person ("data subject"); an identifiable natural person is a person who can be identified, directly or indirectly, in particular on the basis of an identifier such as name and surname, identification number, location data, online identifier or one or more specific physical, physiological, genetic, mental factors, the economic, cultural or social identity of a natural person

Processing - means an operation or a set of operations performed on personal data or sets of personal data in an automated or non-automated manner, such as collecting, recording, organizing, organizing, storing, adapting or modifying, downloading, viewing, using, disclosing by sending, disseminating or otherwise such as sharing, matching or combining, restricting, erasing or destroying;

Restriction of processing - means the marking of stored personal data in order to limit their future processing

Profiling - means any form of automated processing of personal data, which consists in the use of personal data to evaluate certain personal factors of a natural person, in particular to analyze or predict aspects regarding the effects of this natural person's work, economic situation, health, personal preferences, interests, credibility , behaviour, location or movement

Consent - the consent of the data subject means a voluntary, specific, conscious and unambiguous indication of will, by which the data subject, in the form of a statement or a clear affirmative action, consents to the processing of personal data concerning him

Breach of personal data protection - means a breach of security leading to accidental or unlawful destruction, loss, modification, unauthorized disclosure or unauthorized access to personal data sent, stored or otherwise processed

Pseudonymisation - means the processing of personal data in such a way that they can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is stored separately and is covered by technical and organizational measures that prevent its attribution to an identified or an identifiable natural person

Anonymization - Data anonymization is an irreversible data operation process that destroys / overwrites "personal data" making it impossible to identify or link a given record to a specific user or individual.

§2 Data Protection Inspector

Pursuant to Art. 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

In matters relating to data processing, including personal data, you should contact the Administrator directly.

§3 Types of Cookie Files

Internal cookies - files placed and read from the User's Device by the Website's ICT system

External cookies - files placed and read from the User's Device by ICT systems of external websites. Scripts of external websites that may place cookies on the User's Devices have been consciously placed on the Website through scripts and services made available and installed on the Website

Session cookies - files placed and read from the User's Device by the Website during one session of a given Device. After the session ends, the files are deleted from the User's Device.

Persistent cookies - files placed and read from the User's Device by the Website until they are manually deleted. The files are not deleted automatically after the end of the Device session, unless the configuration of the User's Device is set to delete cookies after the end of the Device session.

§4 Security of data storage

Mechanisms for storing and reading cookies - Mechanisms for storing, reading and exchanging data between Cookies saved on the User's Device and the Website are implemented through built-in mechanisms of web browsers and do not allow downloading other data from the User's Device or data from other websites visited by the User, including personal or confidential information. Transferring viruses, Trojan horses and other worms to the User's Device is also practically impossible.

Internal cookies - Cookies used by the Administrator are safe for Users' Devices and do not contain scripts, content or information that may threaten the security of personal data or the security of the Device used by the User.

External cookies - The Administrator makes all possible actions to verify and select website partners in the context of Users' security. The administrator selects well-known, large partners with global social trust for cooperation. However, it does not have full control over the content of Cookies from external partners. The Administrator is not responsible for the security of Cookie files, their content and license-compliant use by Scripts installed on the website, coming from external websites, the Administrator is not responsible as far as the law allows. The list of partners is included in the further part of the Privacy Policy.

Cookie control

The user may, at any time, independently change the settings for saving, deleting and accessing the data of saved Cookies by each website

Information on how to disable cookies in the most popular computer browsers is available on the website: how to disable cookies or from one of the indicated providers:

The User may at any time delete all Cookie files saved so far using the tools of the User's Device through which the User uses the services of the Website.

Threats on the part of the User - The Administrator uses all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of this data depends on both parties, including the User's activity. The Administrator is not responsible for the interception of such data, impersonation of the User's session or their removal as a result of the User's conscious or unconscious activity, viruses, Trojan horses and other spyware that may have infected the User's Device. In order to protect themselves against these threats, users should comply with the rules of using the network .

Storage of personal data - the Administrator ensures that he makes every effort to ensure that the processed personal data entered voluntarily by Users is safe, access to them is limited and implemented in accordance with their purpose and purposes of processing. The administrator also ensures that he makes every effort to protect the data held against loss by using appropriate physical and organizational security measures.

§5 Purposes for which Cookies are used

  • Streamlining and facilitating access to the Website
  • Personalization of the Website for Users
  • Marketing, Remarketing on external websites
  • advertising serving services
  • Keeping statistics (users, number of visits, types of devices, connection, etc.)

§6 Purposes of personal data processing

Personal data voluntarily provided by Users is processed for one of the following purposes:

  • Implementation of electronic services:
    • Services for sharing information about the content posted on the Website on social networking sites or other websites.
  • Administrator's communication with Users in matters related to the Website and data protection
  • Ensuring the legitimate interest of the Administrator

Data about Users collected anonymously and automatically are processed for one of the following purposes:

  • Keeping statistics
  • Remarketing
  • Serving advertisements tailored to Users' preferences
  • Ensuring the legitimate interest of the Administrator

§7 Cookie files of external websites

The Administrator on the Website uses javascript scripts and web components of partners who can place their own cookies on the User's Device. Remember that in your browser settings you can decide for yourself about the allowed cookies that can be used by individual websites. Below is a list of partners or their services implemented on the Website that may place cookies:

Services provided by third parties are beyond the control of the Administrator. These entities may change their terms of service, privacy policy, the purpose of data processing and the ways of using cookies at any time.

§8 Types of collected data

The website collects data about Users. Part of the data is collected automatically and anonymously, and part of the data is personal data provided voluntarily by Users when subscribing to individual services offered by the Website.

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Opened subpages of the website
  • Time spent on the relevant subpage of the website
  • The type of operating system
  • The address of the previous subpage
  • Referrer address
  • Browser language
  • Internet connection speed
  • Internet Service Provider

Data collected during registration:

  • E-mail adress
  • IP address (collected automatically)

Data collected when subscribing to the Newsletter service

  • E-mail adress

Part of the data (without identifying data) may be stored in cookies. Part of the data (without identifying data) may be transferred to the provider of statistical services.

§9 Access to personal data by third parties

As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided are not transferred or resold to third parties.

Access to data (usually on the basis of a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the website, i.e.:

  • Hosting companies that provide hosting or related services for the Administrator

Entrusting the processing of personal data - Hosting, VPS or Dedicated Servers

In order to run the website, the Administrator uses the services of an external hosting provider, VPS or Dedicated Servers - OVH sp. z oo . All data collected and processed on the website are stored and processed in the infrastructure of the service provider located in Poland. It is possible to access data as a result of service work carried out by the service provider's personnel. Access to this data is governed by the agreement concluded between the Administrator and the Service Provider.


§10 Method of personal data processing

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union, unless they have been published as a result of the User's individual action (e.g. entering a comment or entry), which will make the data available to every person visiting the website.
  • Personal data will not be used for automated decision making (profiling).
  • Personal data will not be sold to third parties.

Anonymous data (without personal data) collected automatically:

  • Anonymous data (without personal data) will be transferred outside the European Union.
  • Anonymous data (without personal data) will not be used for automated decision making (profiling).
  • Anonymous data (without personal data) will not be sold to third parties.

§11 Legal basis for the processing of personal data

The website collects and processes Users' data on the basis of:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
    • article 6 sec. 1 lit. and
      the data subject has consented to the processing of his personal data for one or more specific purposes
    • article 6 sec. 1 lit. b
      processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract
    • article 6 sec. 1 lit. f
      processing is necessary for the purposes of legitimate interests pursued by the administrator or by a third party
  • Act of 10 May 2018 on the protection of personal data (Journal of Laws of 2018, item 1000)
  • Act of July 16, 2004 Telecommunications Law (Journal of Laws of 2004, No. 171, item 1800)
  • Act of February 4, 1994 on copyright and related rights (Journal of Laws 1994 No. 24 item 83)

§12 Period of personal data processing

Personal data provided voluntarily by Users:

As a rule, the indicated personal data are stored only for the period of providing the Service as part of the Website by the Administrator. They are deleted or anonymized within 30 days from the end of the provision of services (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

The exception is a situation that requires securing legally justified purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data from the time the User requests their removal, no longer than for a period of 3 years in the event of a violation or suspected violation of the provisions of the website regulations by the User.

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, which are not personal data, are stored by the Administrator in order to keep website statistics for an indefinite period of time.

§13 Users' rights related to the processing of personal data

The website collects and processes Users' data on the basis of:

Right of access to personal data
Users have the right to access their personal data at the request of the Administrator

Right to rectification of personal data
Users have the right to request the Administrator to immediately rectify personal data that is incorrect or / and to supplement incomplete personal data, carried out at the request submitted to the Administrator

The right to delete personal data
Users have the right to request the Administrator to immediately delete personal data, carried out at the request submitted to the Administrator. The Administrator reserves the right to suspend the execution of the request to delete data in order to protect the Administrator's legitimate interest (e.g. when the User has violated the Regulations or the data was obtained as a result of correspondence).
In the case of the Newsletter service, the User has the option of removing their personal data by using the link in each sent e-mail.

The right to limit the processing of personal data
Users have the right to limit the processing of personal data in the cases indicated in art. 18 GDPR, e.g. questioning the correctness of personal data, carried out at the request submitted to the Administrator

The right to transfer personal data
Users have the right to obtain from the Administrator personal data concerning the User in a structured, commonly used machine-readable format, carried out at the request submitted to the Administrator

The right to object to the processing of personal data
Users have the right to object to the processing of their personal data in the cases specified in art. 21 of the GDPR, carried out at the request submitted to the Administrator

Right to lodge a complaint
Users have the right to lodge a complaint with the supervisory body dealing with the protection of personal data.

§14 Contact to the Administrator

The Administrator can be contacted in one of the following ways

Postal address - SEOPoint Adam Pokora, Sportowa 18

E-mail address - kontakt@country-atlas.com

Contact form - available at: /contact

§15 Service Requirements

Restricting the storage and access to cookies on the User's Device may result in incorrect operation of some of the Website's functions.

The Administrator bears no responsibility for incorrectly functioning Website functions if the User restricts in any way the ability to save and read Cookie files.

§16 External links

The Website - articles, posts, entries or comments of Users may contain links to external websites with which the Website Owner does not cooperate. These links and the pages or files indicated under them may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for the content outside the Website.

§17 Changes to the Privacy Policy

The Administrator reserves the right to change this Privacy Policy at any time without the need to inform the Users about the use and use of anonymous data or the use of Cookies.

The Administrator reserves the right to change this Privacy Policy at any time regarding the processing of Personal Data, about which he will inform Users who have user accounts or subscribed to the newsletter service via e-mail within 7 days of changing the records. Further use of the services means that you have read and accepted the changes to the Privacy Policy. In the event that the User does not agree with the introduced changes, he is obliged to delete his account from the Website or unsubscribe from the Newsletter service.

The introduced changes to the Privacy Policy will be published on this subpage of the Website.

The introduced changes enter into force upon their publication.

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